throbber
IPR2016-00739
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`
`
`SAMSUNG ELECTORNICS, CO., LTD., SAMSUNG ELECTRONICS AMERICA,
`INC., AND SAMSUNG SEMICONDUCTOR, INC.,
`Petitioners
`
`v.
`
`RAYTHEON COMPANY,
`Patent Owner
`_______________
`
`Case IPR2016-00739
`
`Patent 5,591,678
`_______________
`
`PRELIMINARY RESPONSE TO PETITION FOR INTER PARTES
`REVIEW OF U.S. PATENT NO. 5,591,678
`
`
`
`
`

`
`IPR2016-00739
`
`EXHIBIT
`
`2001
`
`EXHIBIT LIST
`
`
`DESCRIPTION
`
`Defendants’ Invalidity Contentions and Disclosures
`Pursuant to Patent Rules 3-3 and 3-4, October 2, 2015
`
`i
`
`

`
`TABLE OF CONTENTS
`
`IPR2016-00739
`
`Page(s)
`
`I. 
`
`II. 
`
`INTRODUCTION ........................................................................................... 1 
`
`’678 PATENT BACKGROUND .................................................................... 2 
`
`III.  RELEVANT RELATED MATTERS ............................................................. 3 
`
`A.  District Court Litigation ........................................................................ 3 
`
`B. 
`
`C. 
`
`D. 
`
`E. 
`
`IPR 2015-01201 .................................................................................... 4 
`
`IPR2016-00209 ..................................................................................... 5 
`
`IPR2016-00739 ..................................................................................... 6 
`
`Petitioners Are Attempting to Frustrate the Litigation ......................... 8 
`
`IV.  THE BOARD SHOULD DENY INSTITUTION ........................................... 9 
`
`V. 
`
`CONCLUSION .............................................................................................. 13 
`
`ii
`
`

`
`TABLE OF AUTHORITIES
`
`IPR2016-00739
`
` Page(s)
`
`Cases
`Butamax Advanced Biofuels LLC v. Gevo, Inc.,
`IPR2014-00581, Paper 8 (PTAB October 14, 2014) ................................ 9, 12-13
`
`In re Giacomini,
`612 F.3d 1380 (Fed. Cir. 2010) ............................................................................ 7
`
`In re Hilmer,
`359 F.2d 859 (1966) .............................................................................................. 7
`
`Intelligent Bio-Systems, Inc. v. Illumina Cambridge Limited,
`IPR2013-00324, Paper 19 (PTAB November 21, 2013) .......................... 9, 11, 12
`
`LG Electronics, Inc. v. ATI Technologies ULC,
`IPR2015-00327, Paper 15 (PTAB September 2, 2015).................................. 9, 11
`
`Medtronic, Inc. v. Nuvasive, Inc.,
`IPR2014-00487, Paper 8 (PTAB September 11, 2014)...................................... 10
`
`Unilever, Inc. v. The Procter & Gamble Co.
`IPR2014-00506, Paper 17 (PTAB July 7, 2014) ............................................ 9, 12
`
`Statutes
`
`35 U.S.C. § 102(e) ..................................................................................................... 4
`
`35 U.S.C. § 313 .......................................................................................................... 1
`
`35 U.S.C. §314(a) ................................................................................................ 9, 11
`
`35 U.S.C. § 325(d) ................................................................................................. 1, 9
`
`Other Authorities
`
`37 C.F.R. § 42.107 ..................................................................................................... 1
`
`37 C.F.R. § 42.108(a) ........................................................................................... 1, 11
`
`
`
`iii
`
`

`
`IPR2016-00739
`
`Raytheon Company (“Patent Owner”), respectfully submits this Preliminary
`
`Response to the Petition seeking inter partes review of U.S. Patent No. 5,591,678
`
`(the “’678 Patent”). This filing is timely under 35 U.S.C. § 313 and 37 C.F.R. §
`
`42.107, because it is within three months of the March 21, 2016 date of the Notice
`
`granting the Petition a filing date. IPR2016-00739, Paper 4.
`
`I.
`
`INTRODUCTION
`Patent Owner respectfully submits that the Board should deny inter partes
`
`review of the ’678 Patent under 35 U.S.C. §§ 314(a) and 325(d) and 37 C.F.R. §
`
`42.108(a). In two different proceedings, the Board has already instituted inter
`
`partes review of claims 1-18 of the ’678 patent – the same claims challenged in the
`
`present proceeding – based on fourteen (14) separate grounds. Petitioner has not
`
`explained how the present Petition does not include substantially the same
`
`arguments as those contained in the already-pending IPRs. Rather a review of the
`
`Petition shows it raises the same arguments that are being reviewed in the
`
`instituted IPRs, including arguments that will be rendered moot by the pending
`
`IPRs. The present Petition is yet another part of a serial IPR filing strategy being
`
`employed by Petitioner and other parties accused of infringing the ’678 Patent.
`
`By filing this Petition almost ten months after the first of numerous petitions
`
`filed by cooperating defendants, Petitioner and the three other co-defendants are
`
`relying upon this redundant petition to gain a tactical advantage in extending a stay
`
`1
`
`

`
`IPR2016-00739
`
`of the underlying litigation for an indeterminate time beyond the December 2016
`
`final decision date already set for the first IPR.
`
`Patent Owner should not be subject to this serial petition strategy. Rather,
`
`given that Petitioner has (1) failed to distinguish the teachings of the references it
`
`relies on from those relied on for the two instituted IPRs, and (2) filed its Petition
`
`after the decision granting institution in the first IPR, thereby receiving the benefit
`
`of the Board’s institution decision, the Board should exercise its discretion to deny
`
`this third Petition. Petitioner and the other codefendants should not be allowed to
`
`misuse the IPR process in an attempt to gain a tactical advantage in the underlying
`
`litigation.
`
`II.
`
`’678 PATENT BACKGROUND
`
`The ’678 Patent, titled “Process of Manufacturing a Microelectronic Device
`
`Using a Removable Support Substrate and Etch-Stop,” relates to a method for
`
`making a semiconductor developed by engineers at Hughes Corporation (later
`
`acquired by Raytheon). Ex. 1001.
`
`The inventors of the ’678 Patent, working to improve semiconductors for
`
`navigation and national defense applications, realized that enabling access to the
`
`back side of a micro-circuit could improve the detection of radiation and light rays,
`
`and provide a foundation for stacking other micro-circuits. But gaining access to
`
`the back side without destroying the fragile and expensive thin micro-circuits was
`
`2
`
`

`
`IPR2016-00739
`
`a problem. Their solution was to create a novel fabrication method that would
`
`transfer the thin and fragile micro-circuit and wafer from one support to another
`
`and then remove the back-side support through the use of an etch stop. Their
`
`patented method permits, inter alia, the fabrication of high resolution image
`
`sensors known as back-side illuminated sensors. Raytheon has used the invention
`
`in the ’678 Patent to make high-resolution image sensors for defense and space
`
`applications. Many years after the invention, manufacturers of cameras,
`
`computers, and smart phones, in an effort to improve the resolution of cameras in
`
`their devices, began using sensors made by the inventive process claimed in the
`
`’678 Patent.
`
`III. RELEVANT RELATED MATTERS
`A. District Court Litigation
`Patent Owner asserted the ’678 Patent against Petitioner and several other
`
`defendants in Raytheon Company v. Sony Corporation, et al., C.A. No. 2:15-cv-
`
`342, (E.D. Tex.) and Raytheon Company v. Samsung Electronics Co., Ltd. et al.,
`
`C.A. No. 2-15-cv-00341 (E.D. Tex.) (collectively referred to as the “Litigation”).
`
`Both cases were filed March 6, 2015 and remain pending. Despite Patent Owner’s
`
`opposition, the Litigation was stayed pending resolution of IPR2015-01201, the
`
`first of the serial IPRs filed by the defendants. Ex. 1002.
`
`3
`
`

`
`IPR2016-00739
`
`The defendants in the Litigation, including Petitioner, are coordinating with
`
`respect to defenses, and submitted joint invalidity contentions asserting that the
`
`’678 Patent is invalid as anticipated and/or obvious in light of eighty (80) alleged
`
`prior art references. Ex. 2001.
`
`IPR 2015-01201
`
`B.
`On May 14, 2015, Sony (one of the cooperating defendants) filed a petition
`
`for inter partes review of claims 1-18 of the ’678 Patent, alleging six separate
`
`grounds based on eleven different references. IPR2015-01201, Paper 2, at pp. 2,
`
`36. All of the references relied on by Sony were cited in the joint invalidity
`
`contentions served in the Litigation. Compare Ex. 2001 Defendants’ Joint
`
`Invalidity Contentions, pp. 7-9 (relevant portions highlighted). On December 3,
`
`2015, the Board instituted review of claims 1-18 based on six grounds and
`
`numerous references. IPR2015-01201, Paper 6, at pp. 23-24 (referred to herein as
`
`the “1201 IPR”).
`
`Patent Owner filed its Response in the 1201 IPR on March 11, 2016.
`
`IPR2015-01201, Paper 22. With its Response, Patent Owner submitted evidence
`
`to establish that it conceived of, and reduced to practice, the inventions of the ’678
`
`Patent prior to the effective date of Bertin, a 35 U.S.C. § 102(e) reference that had
`
`been relied upon by Sony as a primary reference. IPR2015-01201, Paper 22, p. 2.
`
`4
`
`

`
`IPR2016-00739
`
`C.
`IPR2016-00209
`On November 18, 2015, Sony filed a petition for inter partes review of
`
`claims 1-18 of the ’678 Patent, alleging eight separate grounds based on seven
`
`references. IPR2016-00209, Paper 2 at pp. 2-3 (referred to herein as the “0209
`
`IPR”). All of the references supporting the grounds in the Petition were cited
`
`either in the joint invalidity contentions served in the Litigation on October 2, 2015
`
`or the ’678 Patent’s file wrapper, served on July 16, 2015. See Ex. 2001, pp. 7-8;
`
`see also IPR2016-00209, Exs. 1009, 1011 at p. 5.1 Patent Owner opposed
`
`institution because, inter alia, Sony had failed to establish that the validity
`
`challenges were not redundant of those in the 1201 IPR. IPR2016-00209, Paper 10
`
`at 1. In its decision instituting the IPR, the Board explained that institution was
`
`appropriate because (1) the principal reference in the 1201 IPR was 102(e) prior art
`
`whereas the principal reference in the 0209 IPR was 102(b) prior art, and (2)
`
`Petitioner did not have the benefit of the institution decision in the 1201 IPR in
`
`preparing its Petition. IPR2016-00209, Paper 12 at 8-9. As explained more fully
`
`below, neither scenario is present here.
`
`
`1 U.S. Patent No. 4,169,000 (“Riseman II”) cited in the ’678 Patent’s file
`
`wrapper is a division of Ex. 1009 (“Riseman”) and contains the same disclosures.
`
`5
`
`

`
`IPR2016-00739
`
`Accordingly, the ’678 Patent is currently under review, based on fourteen
`
`separate grounds and numerous prior art references, in the 1201 and 0209 IPRs.
`
`IPR2016-00739
`
`D.
`On March 10, 2016, almost ten months after the filing of the 1201 IPR
`
`petition, and over three months after the decision instituting the 1201 IPR,
`
`Petitioners filed the present IPR Petition. IPR2016-00739, Paper 1. The Petition
`
`seeks review of claims 1-18 of the ’678 Patent – the same claims already under
`
`review in the two previous IPRs – based on seven separate grounds and numerous
`
`prior art references. Id. at pp. 4-5. The primary references relied on by Petitioner,
`
`Takahashi and Cade, were cited in the joint invalidity contentions served in the
`
`Litigation. Compare Ex. 2001 at pp. 7, 9, Ex. 1005, and Ex.1006. While the
`
`Petition contains an assertion that the grounds in its Petition are not redundant of
`
`each other, it contains no assertion or explanation on how its validity challenges
`
`are not redundant of the grounds pending in the 1201 and 0209 IPRs. Paper 1 at
`
`59. Petitioner gives no explanation as to any specific differences between the
`
`arguments advanced in its Petition or between the teachings of the references
`
`supporting the validity challenges in the present Petition versus the references at
`
`issue in the already-pending IPRs.
`
`Further, one of the primary references relied on by Petitioner is Takahashi,
`
`which Petitioner alleges is prior art under 102(e). Paper 1 at 4-55. The effective
`
`6
`
`

`
`IPR2016-00739
`
`date of Takahashi, however, is after the effective date of Bertin, the primary 102(e)
`
`reference from the 1201 IPR. Compare Paper 1 at 4. (identifying November 13,
`
`1991 as the filing date for Takahashi) with IPR2015-01201, Ex. 1017 (Bertin filing
`
`date: September 13, 1991).2 Accordingly, the 102(e) issues in the present Petition
`
`are redundant of, and will be rendered moot by, the 102(e) issues in the 1201 IPR.
`
`In addition, Petitioner asserts that its other primary reference, Cade, is prior
`
`art under 102(b). Paper 1 at 4. But Petitioner provides no explanation for how its
`
`assertions regarding Cade are not substantially the same as the grounds pending
`
`under, for example, Morimoto (in the 1201 IPR) or Liu (in the 0209 IPR), both of
`
`which are alleged to be 102(b) references. IPR2015-01201, Paper 2 at 8; IPR2016-
`
`00209, Paper 2 at 10. Indeed, Petitioner does not identify any alleged distinction
`
`between Cade and the prior art of record in the pending IPRs.
`
`
`2 The face of Takahashi lists foreign priority documents but the effective
`
`date under 102(e) of a U.S. Patent is its filing date in the United States, not its
`
`foreign priority date. See In re Giacomini, 612 F.3d 1380, 1384 (Fed. Cir. 2010),
`
`citing In re Hilmer, 359 F.2d 859 (1966).
`
`7
`
`

`
`IPR2016-00739
`
`As explained herein, the Board should deny the present Petition because it is
`
`a serial IPR filing3 that presents the same or substantially the same arguments that
`
`are already pending in previously instituted IPRs.
`
`Petitioners Are Attempting to Frustrate the Litigation
`
`E.
`The serial petitions show that the IPR procedure is being used to gain a
`
`tactical advantage in the Litigation. The underlying Litigation was stayed pending
`
`the 1201 IPR, which is set for a hearing on October 13, 2016. IPR2015-01201,
`
`Paper 35. Patent Owner believes that Petitioner filed the present IPR as a tactical
`
`measure to extend the stay and frustrate Patent Owner’s efforts to enforce the ’678
`
`patent. As previously explained, the primary references cited in the present
`
`petition were known to Petitioner no later, and likely much earlier, than October 2,
`
`2015. See Exhibit 2002 pp. 7-9. Petitioner offers no reason why it waited almost
`
`10 months from the filing of the 1201 IPR, and over 5 months from the service of
`
`the invalidity contentions, to file the present Petition. Petitioner makes no
`
`allegation that any of the prior art references supporting its contentions were
`
`
`3 Consistent with the defendants’ strategy, on April 28, 2016, Petitioners
`
`filed another IPR Petition, the fourth attack on the ’678 Patent. See IPR2016-
`
`00962.
`
`8
`
`

`
`IPR2016-00739
`
`recently found. Petitioner offers no explanation for why it could not have filed
`
`earlier.
`
`IV. THE BOARD SHOULD DENY INSTITUTION
`The Board has discretion on whether to institute an IPR. Intelligent Bio-
`
`Systems, Inc. v. Illumina Cambridge Limited, IPR2013-00324, Paper 19, at 4
`
`(PTAB November 21, 2013) (“Congress made institution discretionary.”); see also
`
`35 U.S.C. §314(a). In determining whether to institute, the Board may deny
`
`institution on some or all grounds for unpatentability, and may deny institution for
`
`some or all challenged claims. Id. Further, the Board can reject a petition where
`
`the same or substantially the same arguments were previously presented. Id.
`
`(citing 35 U.S.C. § 325(d)).
`
`The Board has routinely denied petitions where the Petitioner has failed to
`
`establish that the arguments in a second petition are not substantially the same as,
`
`or cumulative to, arguments made in a first petition. See, e.g., LG Electronics, Inc.
`
`v. ATI Technologies ULC, IPR2015-00327, Paper 15, at 2-4 (PTAB September 2,
`
`2015); Unilever, Inc. v. Procter Gamble Co., IPR2014-00506, Paper 17, at 6
`
`(PTAB July 7, 2014); IPR2013-00324, Paper 19, at 5-6. The Board has noted the
`
`impropriety of allowing petitioners to present serial challenges against Patent
`
`Owners. See Butamax Advanced Biofuels LLC v. Gevo, Inc., IPR2014-00581,
`
`Paper 8, at 13 (PTAB October 14, 2014) (“Allowing similar serial challenges to the
`
`9
`
`

`
`IPR2016-00739
`
`same patent, by the same petitioner, risks harassment of patent owners and
`
`frustration of Congress’s intent in enacting the Leahy-Smith America Invents
`
`Act.”)
`
`As previously explained, the present Petition challenges the same claims of
`
`the ’678 Patent as those that are already at issue in the 1201 and 0209 IPRs that
`
`was instituted on multiple grounds and numerous references. Petitioner made no
`
`effort to distinguish the teachings of the references relied on in the present Petition
`
`from those that support the grounds in the 1201 and 0209 IPRs.
`
`The Petition contains a short paragraph addressing redundancy, but
`
`Petitioner merely alleges that the grounds within the petition are not redundant of
`
`each other. Paper 1 at 59. The Petition, however, makes no showing that the
`
`alleged grounds are not substantially similar to those already pending in the 1201
`
`and 0209 IPRs. See, e.g., Medtronic, Inc. v. Nuvasive, Inc., IPR2014-00487, Paper
`
`8 at 6 (PTAB September 11, 2014) (“While Petitioner argues that the grounds are
`
`not redundant to those instituted on in the ‘506 Proceeding, Petitioner does not
`
`provide any specific reasoning to support that argument….”). More specifically,
`
`the Petition makes no showing that the grounds alleged under Takahashi under
`
`102(e) are not substantially similar to the grounds alleged under Bertin under
`
`102(e) in the 1201 IPR. Indeed, as explained above, the grounds under Takahashi
`
`are redundant of, and rendered moot by, the grounds under Bertin because Patent
`
`10
`
`

`
`IPR2016-00739
`
`Owner has submitted evidence in the 1201 IPR to predate Bertin, which has an
`
`earlier effective date than Takahashi. Petitioner also has made no showing that its
`
`allegations regarding Cade are not substantially the same as the allegations pending
`
`with respect to other 102(b) art before the Board in the 1201 and 0209 IPRs,
`
`including Liu and Morimoto.
`
`In addition, Petitioner has not established that its alleged grounds are
`
`substantially different merely because it relies on different prior art references than
`
`are at issue in the 1201 and 0209 IPRs. A petitioner cannot establish that its
`
`challenges are not redundant simply by relying on a different primary reference.
`
`See, e.g., IPR2015-00327, Paper 15, at 2 (“Notwithstanding Petitioner’s
`
`application of different primary references, in view of the overlapping arguments
`
`and our institution of inter partes review of the same claims in the Companion
`
`Case, we exercised our discretion under 35 U.S.C. § 314(a) and 37 C.F.R. § 42.108
`
`(a) and declined to institute against the same claims in this proceeding.”);
`
`IPR2014-00487, Paper 8 at 6 (“While Petitioner argues that the grounds are not
`
`redundant to those instituted on in the ‘506 Proceeding, Petitioner does not provide
`
`any specific reasoning to support that argument, other than to state that the
`
`grounds are based on different prior art references.”) (emphasis added ).
`
`In IPR2013-00324, the Board denied institution of a second IPR, where --
`
`like the scenario here -- the second Petition was based on a different primary
`
`11
`
`

`
`IPR2016-00739
`
`reference as a first IPR that had been instituted, and Petitioner had not adequately
`
`distinguished the primary reference of the second petition from those involved in
`
`the first IPR. IPR2013-00324, Paper 19, at 4-6. Specifically, the Board stated the
`
`following:
`
`Furthermore, we note that IBS [Petitioner] has not provided any
`justification for filing the instant petition, other than its representation
`that it became aware of the relevance of Odedra after the filing of the
`128 Petition. Pet. 2. IBS does not distinguish any teaching present
`in Odedra that is lacking from Ju, Tsien, or any of the other
`references cited in the 128 Petition. We therefore conclude that the
`128 Petition presented the same, or substantially the same, prior art
`and arguments to the Office as those in the instant petition.
`Id., at 6-7 (emphasis added).
`
`Similarly, in the present Petition, Petitioner has made no effort to distinguish
`
`the teachings of Takahashi or Cade from Bertin, Liu, Morimoto, or any of the other
`
`many references cited in the petitions in the 1201 and 0209 IPRs. Thus, as in
`
`IPR2013-00324, the Board should also deny the Petition in this proceeding.
`
`In addition, the present Petition was filed several months after institution of
`
`the 1201 IPR. Accordingly, Petitioners had the benefit of the institution decision,
`
`and the Board has denied serial IPR Petitions that have come after the benefit of
`
`institution decisions. IPR2014-00581, Paper 8 at 12-13 (denying institution where
`
`Petitioner was able to use a prior institution decision as a roadmap); IPR2014-
`
`12
`
`

`
`IPR2016-00739
`
`00506, Paper 17 at 8 (same). As previously explained, Petitioner could have filed
`
`its Petition many months ago, and offered no explanation for why it did not do so.
`
`Patent Owner should not be subjected to a late-filed serial petition that is not
`
`substantially different from the fourteen other grounds from other already-pending
`
`IPRs.
`
`V. CONCLUSION
`The Petition is a strategic third bite at the apple that is intended to burden
`
`Patent Owner and/or lengthen a stay in the underlying Litigation. Petitioner has
`
`not adequately distinguished the arguments or teachings in the references in the
`
`Petition from those already at issue in the 1201 and 0209 IPRs, in which all claims
`
`of the ’678 patent are under review on multiple grounds. Accordingly, the Board
`
`should deny institution of the present Petition.
`
`
`
`13
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`

`
`IPR2016-00739
`
`
`
`Respectfully submitted,
`
`/Thomas J. Filarski Reg No 31612/
`Thomas J. Filarski
`Reg. No. 31,612
`tfilarski@steptoe.com
`John L. Abramic
`Reg. No. 51,031
`jabramic@steptoe.com
`Daniel S. Stringfield
`Reg. No. 68,677
`dstringfield@steptoe.com
`Brian Fahrenbach
`Reg. No. 72,603
`bfahrenbach@steptoe.com
`STEPTOE & JOHNSON, LLP
`115 South LaSalle Street, Suite 3100
`Chicago, IL 60603
`Telephone: 312-577-1300
`Facsimile: 312-577-1370
`
`Counsel for Raytheon Company
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`14
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`Date: June 21, 2016
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`Customer Number: 27890
`STEPTOE & JOHNSON LLP
`115 S. LaSalle St.
`Chicago, IL 60603
`Telephone: (312) 577-1252
`Facsimile: (312) 577-1370
`
`

`
`IPR2016-00739
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned hereby certifies that a copy of the foregoing
`
`PRELIMINARY RESPONSE TO PETITION FOR INTER PARTES
`
`REVIEW OF U.S. PATENT NO. 5,591,678, was served in its entirety on June
`
`21, 2016 by filing this document through the Patent Review Processing System as
`
`well as by delivering a copy via electronic email to the attorneys of record for the
`
` Heath J. Briggs (Reg. No. 54,919)
`Greenberg Traurig, LLP
`1200 17th Street, Suite 2400
`Denver, CO 80202
`Email: briggsh@gtlaw.com
`
`Patrick J. McCarthy (Reg. No. 62,762)
`Greenberg Traurig, LLP
`2101 L Street NW, Ste. 1000
`Washington, DC 20037
`Email: mccarthyp@gtlaw.com
`
`By:
`
`/Thomas J. Filarski, Reg No. 31612/
`Thomas J. Filarski
`Registration No. 31,612
`Steptoe & Johnson LLP
`115 S. LaSalle St.
`Chicago, IL 60603
`Telephone: 312-577-1252
`Facsimile:
`312-577-1370
`
`Counsel for Raytheon Company
`
`Patent Owner’s as follows:
`
`
`
`
`
`Date: June 21, 2016

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